Environmental Effects Report Expansion of Pyrethrum ... · hexane losses. The most significant...

Environmental Effects Report

Expansion of Pyrethrum Extraction Processing Operations

For

Botanical Resources Australia – Manufacturing Services Pty Ltd

October 2010

Prepared by Environmental Service and Design Pty Ltd ABN 97 107 517 144 ACN 107 517 144 Office 14 Cattley Street Burnie TAS 7320 Phone: (03) 6431 2999 Fax : (03) 6431 2933 www.esandd.com.au

Postal PO Box 651 Burnie TAS 7320 ProjectNo. 4364

BRA EER Duplication of extraction process operations – October 2010

Environmental Service and Design Pty Ltd – PAF#4364

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Document Control

Prepared & Published by: ES&D

Version: Final

File: 4364

Contact: Greg Doherty

Phone No: (03) 6431 2999

Prepared For: BRA

Version: Reviewed/Approved By Date

Draft Greg Doherty, ES&D 11-Feb-10

Draft 2 Greg Doherty, ES&D 25 April-10

Draft 3 Greg Doherty, ES&D 8-Aug-10

Final Greg Doherty, ES&D 23-August-10

Updated Greg Doherty, ES&D 20-Sep-10

Updated Greg Doherty, ES&D 4-Oct-10

Updated Greg Doherty, ES&D 14-Oct-10

This report has been prepared, based on information generated by Environmental Service and Design Pty Ltd from a wide range of sources. If you believe that Environmental Service and Design Pty Ltd has misrepresented or overlooked any relevant information, it is your responsibility to bring this to the attention of Environmental Service and Design Pty Ltd before implementing any of the report’s recommendations.

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Summary

Botanical Resources Australia proposes to expand the pyrethrum extraction capacity at

their Ulverstone plant by building a new 3 tph plant. This will result in an increase in

processing rate from 1.5 tph to 4.5 tph. The increase in processing rate will allow for an

increase in maximum throughput rate from 10,000 tpa to 15,000 tpa.

The new extraction circuit will operate in parallel with the existing extraction circuit and

where ever practical will share some services and infrastructure. A new boiler and

effluent management system will need to be installed along with increased storage of

hexane and an upgrade of fire protection. The new facilities will operate continuously for

5 months of the year, typically January to May.

Models of the combined emissions from a new 2 MW boiler and the existing boiler

(under worst case conditions) indicate that State Government air quality guidelines will

be met for airborne particulate and gaseous emissions from site when discharged from

a 27m high stack. The emissions are forecast to result in PM10 concentrations < 30

µg/m3 (24 hour) and NOx concentrations < 90 µg/m

3 (24 hour) above background

immediately adjacent the premises. The concentrations rapidly dissipate with distance

and are considered negligible within 500 m of the plant. Because of the coastal location

and high exposure to prevailing wind regime the impact of emissions is not considered

to be significant with sufficient capacity in the local air shed to absorb the increased

emissions. Post commissioning stack tests are proposed to confirm the actual

performance compared to emissions models. Contingencies in planning and design of

the plant have also been included for implementation of additional pollution mitigation

strategies if required.

The site will continue to utilise raffinate (vegetable oil by product from extraction

process) as an alternative and primary fuel source for the boiler. This process has the

combined benefit of reducing waste generation and providing beneficial reuse of a

potential waste product. Ongoing use of the raffinate will be supported by programs to

optimize the material as a fuel source that will minimise boiler stack emissions.

Operational improvements over the last 5 years have resulted in significant reduction in

plant hexane losses from 20 to 4.5 L/t, and an improved understanding of the potential

hexane losses. The most significant source of hexane loss (75%) is considered to be

diffuse losses from normal production and maintenance practices associated with

operation of the plant. The improved understanding of hexane losses have been

combined with emission models to provide a robust understanding of plant hexane

emissions. The results of modeling indicate that the worst case offsite ground level

hexane concentrations (2.4 mg/m3) are less than the Tasmanian Environmental

Protection Policy (Air Quality) standard of 6 mg/m3 (3 minute).

Given the quantities of the hexane stored and used the site is a registered Large

Dangerous Substance Location. As a consequence the site has implemented relevant



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engineering and administrative controls. This includes undertaking a dedicated fire risk

management plan and implementing the significant outcomes in the design of the new

plant. This will include improvements to the firefighting capacity and design of the new

plant.

Monitoring of hexane usage, recovery and losses will be ongoing, along with the

improvement of the hexane loss models. Additional monitoring of ambient plant hexane

concentrations combined with measurement of hexane vented from the marc silo will be

undertaken during 2011 to further improve the current loss model.

The increase in production will result in increased vehicle movements. Peak truck

movements will correspond with harvesting of pyrethrum. The harvest typically occurs

during late summer and runs over a 35 day period. Traffic impacts due to harvesting are

therefore short term. To minimize traffic congestion during the harvesting period the site

has installed an additional weigh bridge to improve vehicle flows in and out of the site

along Industrial Drive.

The expansion will also provide an upgrade of water management facilities including

storm water, fire water and process water. Up to 60% of process water will be recycled

and reused to reduce the overall plant consumption from 32 to 12 m3/day. All water not

able to be recycled will be discharged to sewer under a Trade Waste agreement.

Construction of the new extraction plant is planned to occur during 2010 and 2011 to be

ready for the 2011/12 harvest period. A list of management commitments to enable

construction works and ensure the sustainability of the operation is presented below;

Management commitments

No. Item Timing

1.1 Atmospheric Emissions – Particulate and NOx

1.1.1 Based on the results of modeling using the March 2010 stack test results use a 27m high stack for the new boiler.

Design – Underway

1.1.2 Sustain ongoing improvements in the quality of the raffinate fuel to mitigate against particulate emissions.

Design – Underway

1.1.3 Undertake confirmatory stack testing of the existing boiler performance during 2011 (pre commissioning of new boiler).

Pre construction - March 2011

1.1.4 Based on the March 2011 stack test results, and where necessary, update emissions models and review the design of pollution mitigation systems in liaison with the EPA.

Pre construction – May 2011

1.1.5 Undertake post commissioning boiler stack testing of the new boiler and existing boiler (post commissioning).

Post commissioning - January 2012

1.1.6 Based on the outcome of post commissioning stack tests, and if required supported by additional modeling, implement suitable pollution engineering controls to meet the Tasmanian Environmental Protection Policy (Air Quality).

Post commissioning – November 2012



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Management commitments (continued)

No. Item Timing

1.1.7 Investigate Installation of a suitable Continuous Emissions Monitoring System (CEMS) dependent upon the results of post commissioning stack tests and effectiveness of pollution control mitigation strategies.

If required post commissioning – November 2012

1.1.8 Undertake ongoing annual boiler stack emission tests to confirm performance of both boilers and pollution mitigation strategies.

Annual

1.2 Atmospheric Emissions – Hexane

1.2.1 Undertake vent point hexane monitoring to assist improvement of loss models and baseline conditions prior to commissioning. Vent point monitoring locations include – existing boiler stack, existing adsorption column exhaust, marc silo vent stack.

March 2011.

1.2.2 Assessment of suitability for ambient air quality monitoring for VOCs to confirm plant performance

March 2011

1.2.3 Post commissioning vent point hexane monitoring to confirm model inputs reported to EPA. Vent point monitoring locations include – existing boiler stack, new boiler stack, existing adsorption column exhaust, new plant adsorption column exhaust, marc silo vent stack.

Post commissioning

1.2.4 Continuous static workplace hexane LEL monitoring. Ongoing

1.2.5 Annual reporting of hexane losses and updates on activities undertaken to minimise losses, including the results of any monitoring of emissions, coordinated with NPI reporting requirements and submitted to the EPA.

Annual

2.0 Dangerous goods

2.1 Implement WST (2009) guidelines as a Large Dangerous Substance Location

Ongoing

2.2 Sustain safe handling and storage systems, employee and visitor training, suitable signage and demarcation of hazardous substances.

Ongoing

2.3 Periodic review of emergency response plans and training as well as periodic assessment of risks.

Ongoing

3.0 Fire risks

3.1 Upgrade fire management infrastructure as per HAZOP. Prior to commissioning

3.2 Install new pumping system consisting of one diesel and one electric pump, plus a jacking pump.

Prior to commissioning

3.3 Install 150 mm diameter line will be run from the new pumps to the foam sprinkler system for the new plant, plus the new fire hydrants.


3.4 Install a fire water sump to contain run off from fire fighting water.




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No. Item Timing

4.0 Traffic

4.1 Respond to possible changes in traffic conditions on Industrial Drive and utilize Export Drive where necessary during construction.

As required

5.0 Water management

5.1 Construct all new facilities on concrete with sealed surfaces for designated traffic routes.

Design of new plant

5.2 Upgrade effluent treatment system to manage new plant waste water.


5.3 Minimize the use of raw water through reuse and recycling of available streams to minimize the amount sent to sewer.

Ongoing

6.0 Waste management

6.1 Explore alternative beneficial reuse of the marc as a biofuel or biomass.

Ongoing

6.2 Maximise use of raffinate as the primary fuel source through engineering controls dependent upon results of stack monitoring.

Ongoing

7.0 Visual amenity

7.1 Ensure building cladding and exterior is matched wherever practical to the existing facilities to minimize visual impact

Design of new plant

8.0 Heritage

8.1 Halt woks and seek relevant advice if items of potential Aboriginal or European heritage are identified during construction.

Design of new plant

9.0 Decommissioning

9.1 Prepare and submit a decommissioning plan as required by the regulatory authority.

As required

10.0 Construction

10.1 Implement DECC (2009) interim construction noise guidelines (or equivalent). Construction activities will only occur during daylight hours.

During construction

10.2 Utilise Export Drive access during construction to minimize traffic hazards on Industrial drive.

During construction



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Table of contents

Document Control ................................................................................................................................1

Summary ..............................................................................................................................................2

Table of contents ..................................................................................................................................6

List of figures ........................................................................................................................................7

List of tables .........................................................................................................................................7

List of appendices ................................................................................................................................7

1.0 Proponent information ..............................................................................................................8

2.0 Project description ................................................................................................................. 10

2.1 Process description ........................................................................................................... 10

2.2 Project area ....................................................................................................................... 16

3.0 Potential Environmental Effects ............................................................................................ 20

3.1 Air emissions ..................................................................................................................... 20

3.2 Rivers creeks wetlands and estuaries ............................................................................... 27

3.3 Liquid effluent .................................................................................................................... 29

3.4 Solid wastes ...................................................................................................................... 29

3.5 Noise emissions ................................................................................................................ 30

3.6 Transport impacts .............................................................................................................. 31

3.7 Dangerous goods and chemicals ...................................................................................... 32

3.8 Fire risks ............................................................................................................................ 34

3.9 Health risks ........................................................................................................................ 35

3.10 Site contamination ......................................................................................................... 36

3.11 Sustainability and climate change ................................................................................. 36

3.12 Cultural heritage and sites of high public interest ......................................................... 37

3.13 Visual amenity ............................................................................................................... 37

3.14 Decommissioning and rehabilitation .............................................................................. 37

4.0 Management commitments ................................................................................................... 38

5.0 Public consultation................................................................................................................. 41

6.0 References ............................................................................................................................ 42



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List of figures

Figure 1 Botanical Resources Australia manufacturing plant location plan ...............................9

Figure 2 Extraction process flow diagram and terminology ..................................................... 10

Figure 3 Botanical Resources Australia site plan .................................................................... 11

Figure 4 Evaporation process summary .................................................................................. 12

Figure 5 Hexane recovery process summary .......................................................................... 13

Figure 6 Effluent treatment plant ............................................................................................. 15

Figure 7 Botanical Resources Australia manufacturing plant land use and zoning plan ........ 19

Figure 8 TAPM highest predicted PM10 GLCs (24h) ............................................................... 23

Figure 9 TAPM highest predicted Hexane GLCs (3min) ......................................................... 26

Figure 10 Site storm water plan. ................................................................................................ 28

List of tables

Table 1 Relevant Environment Protection Policy NEPM air quality guidelines .......................... 20

Table 2 Existing boiler in-stack monitoring results ..................................................................... 20

Table 3 Composition of Pyrethrum Raffinate ............................................................................. 21

Table 4 Summary of annual hexane losses ............................................................................... 24

Table 5 Hexane losses at 4.5 tph processing (~20.25 L/h emissions) ....................................... 25

Table 6 Summary of typical effluent sources ............................................................................. 29

Table 7 Predicted peak harvest truck movements of raw materials, residue and products ....... 32

Table 8 Bass Highway Traffic Counts* ....................................................................................... 32

Table 9 Summary of BRA Dangerous Goods inventory changes .............................................. 33

Table 10 Summary of BRA Greenhouse Gas emissions ......................................................... 36

Table 11 Management commitments ....................................................................................... 38

List of appendices

Appendix 1 Photographs of visual amenity

Appendix 2 Stack monitoring results

Appendix 3 Emissions modeling report

Appendix 4 Extraction 2 Fire consequence analysis

Appendix 5 EPA EER report guidelines



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1.0 Proponent information

Name: Botanical Resources Australia – Manufacturing Services Pty Ltd

ABN Number: 83 090 620 492

Site Address: 44-46 Industrial Drive, Ulverstone TAS 7315

Postal Address: PO BOX 3251, Ulverstone, TAS 7315

Contact person: Helen Faber – Manager Chemical Processes

Site Phone: (03) 6425 5888

Botanical Resources Australia - Manufacturing Services Pty Ltd (BRA) operates a

facility for processing and testing agricultural crops and for refining pyrethrum oleoresin

at Ulverstone on the north west coast of Tasmania (Figure 1). The production facility is

designated under schedule 2 of EMPCA as a Level 2 Activity.

The growing and harvesting processes in Northern Tasmania have been fostered and

developed by BRA. As a result the industry has expanded and developed as an

alternative cash crop for farmers in the north of the state.

BRA has been based at Ulverstone for 13 years and has operated a pyrethrum refinery

for the past 12 years. The company moved most of its operations (including the

pelletiser) to the site at 44-46 Industrial Drive at the end of 1998. This site was initially

purchased primarily for crop storage in late 1997. A pelletising plant was installed in

1998 and crop storage was greatly expanded in preparation for the 1999/2000 harvest.

In 2002, an extraction facility was commissioned to produce a crude extract from the

plant matter. The refinery capabilities were expanded during 2009.

The current extraction plant has the capacity to process 1.5 tph of pelletised feed and

processes approximately 9000 tonnes per annum during summer months. The

proposed upgrade will increase the processing rate by 3.0 tph to 4.5 tph and increase

total materials processed up to 15,000 tonnes.

This Environmental Effects Report is based on the report guidelines issued by the EPA

to address environmental matters related to the upgrade. A copy of the project specific

guidelines is presented in Appendix 5 of this report.



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Figure 1 Botanical Resources Australia manufacturing plant location plan



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2.0 Project description

2.1 Process description

It is proposed to build a new extraction circuit rated at 3 tph. The new plant will be

operated in parallel to the existing 1.5 tph plant, and share existing peripheral

infrastructure including storage, pellet feed, refinery and utilities. An additional boiler

and cooling tower will be required and the effluent treatment system will be improved. A

process flow diagram is presented as Figure 2. The general location of the proposed

new works is presented in Figure 3.

EXTRACTION PROCESS FLOW DIAGRAM AND TERMINOLOGY

Pellets "Miscella" Clarified Oleoresin to

miscella refinery

Spent

marc

Pellets Pelletised crop of pyrethrum daisies. Pellets are 4 - 6 mm diameter x 5 - 10 mm long

Miscella Solution of pyrethrum (and other extractable material) in hexane. Dark coloured liquid - low viscosity.

Oleoresin Obtained by evaporating off the hexane in the miscella. Mixture of 20 - 30% pyrethrum and 70 - 80% other

organic material. Black, viscous liquid.

Marc Pellets after extraction of pyrethrum. Some pellets remain intact, others disintegrate during the drying process.

Raffinate By product from refinery used as boiler fuel. Black, viscous liquid. Consists mainly of the organic material in the

oleoresin after the pyrethrum has been recovered.

Brats Vessels used to extract the pyrethrum pellets

Pellet

storage

Extractionvessels

("Brats")

Miscella

clarification

Evaporation

- four stages

Marcdryers

Marc

storage

Figure 2 Extraction process flow diagram and terminology

Replication of the extraction plant will provide the following advantages to BRAs

operations;

− Improved product recovery due to faster processing times reducing time available for product degradation.

− Improved plant reliability by having a second extraction unit operating in parallel with the existing extraction plant.

− Reduced unit cost of production due to increased recovery and faster throughput rate.

− Improved utilisation of site utilities and resources.

The proposed project will increase the efficiency of the operation by overcoming

bottlenecks related to the extraction stage of the plant. The proposed modifications will

improve the operating efficiency of the plant by increasing the capacity from 1.5 tph to

4.5 tph of pellets. Raw material throughput rates will increase by 200%.

The current licensed capacity of the operation is 10,000 tpa. BRA processed 8,200

tonne for 2010, which is 82% of the maximum raw material processing limit.



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Total quantities of processed materials are dependent on future market conditions and

the supply of crop materials. It is expected that the plant capacity may increase within

the next 3 years up to 15,000tpa.

Figure 3 Botanical Resources Australia site plan

2.1.1 Extraction process operations

2.1.1.1. Pellet supply

Pellets will be sent from the pellet shed to a small bin located above the first extraction

vessel. The conveying system will consist of a fully enclosed pneumatic conveying

process. From this bin the pellets will be metered to the first extraction vessel via a

screw. The level of the pellets in the chute between the screw and the first extraction

vessel will be controlled to minimise loss of hexane vapour from the chute.

2.1.1.2. Extraction

Extraction will be carried out in 2 - 4 vessels in a continuous, counter current process.

These vessels are known colloquially as ‘brats’. The brats consist of a tank with a

square base with screws mounted side by side in the base of the brat that slowly move

the pellets out to the next brat.

The miscella is pumped into the top of each screw, and then flows slowly down the

screw and then up the tank. It then overflows the tank to the next miscella pump.



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About 95% of the pyrethrum in the pellets will be dissolved, giving a miscella containing

<10 g/L pyrethrum. The miscella will also contain <30 g/L of other hexane soluble

material which is of no commercial value, apart from the value as fuel. The Brats will be

sealed, and hexane vapours ducted to the vapour recovery system.

2.1.1.3. Miscella clarification

The miscella contains a small amount of fine solids which are generated by pellet

breakdown in the pellet handling system. The bulk of these will be removed by settling

in a clarifier, and the sludge sent to a secondary (‘wash’) clarifier to minimise pyrethrum

loss in the sludge. The clarified miscella will then be pumped to a miscella holding tank.

All the vessels described above will be sealed. Vapour emissions from all the vessels

will be collected and ducted to the vapour recovery system.

2.1.1.4. Evaporation of miscella

Evaporation will be carried out in a series of separate evaporators (Figure 4). The first

two will remove the bulk of the hexane and will consist of horizontally mounted forced

circulation shell and tube type evaporators. The miscella will be circulated through the

evaporator tubes, and the thickened miscella/vapour mix will be separated in a cyclone.

The thickened miscella will be returned to the pump inlet.

The clean vapour from both evaporators will be sent to a single shell and tube

condenser mounted horizontally. The condensed vapour will be pumped into the

hexane water separator vessel. A refrigerated cooling tower will be installed to provide

chilled cooling water for the condensers. Using chilled water will assist in the ongoing

improvement of hexane losses.

To ejector

Cooling water

in Cooling water out

Hexane condenser

Evaporator 3

To ejector

Liquid hexane out

Hot hexane

vapour from Evaporator 4

marc dryer Steam and hexane

vapour from ejectors *** To

ejectors

Evaporator 1 Evaporator 2 ***

Oleoresin

Miscella out to

preheater storage

Miscella from

storage tank

Figure 4 Evaporation process summary

The third evaporator will consist of a preheater followed by a vertical column packed

with pall rings. The fourth evaporator will be a wiped film type to reduce the hexane

content of the oleoresin to below 0.5% w/w. Both these evaporators will be a single

pass. All the evaporators will run under vacuum. Steam jet ejectors will be used to

provide the vacuum.



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This elaborate approach is necessary as pyrethrum is heat sensitive and exposure to

temperatures above about 90oC for any length of time results in degradation of the

pyrethrum. A small fraction of the oleoresin produced will be sold as is, but most of the

oleoresin will be sent to the refinery for further processing.

2.1.1.5. Recovery of hexane vapours

Minimising hexane losses and maximising recovery of hexane for reuse within the

extraction plant is a key economic, safety and environmental driver for its operation.

Significant resources are dedicated to prevention of losses, maximising recovery and

monitoring of these aspects of plant performance on short term (continuous) and longer

term (annual) time frames.

To minimise losses all vessels in the extraction and miscella clarification circuit are

designed to be as gastight as possible. To allow for changes in the liquid volume, they

will all be ducted to a vapour header. The hexane and non condensable vapours from

the hex-steam condenser will be ducted to the vapour header. As this vapour stream is

warm and will contain a lot of hexane vapour, it will be cooled in a heat exchanger using

chilled water at 2oC (Figure 5).

The combined vapours will then be sent to the bottom of an absorber column which is

packed with pall rings. As it flows up the column, the hexane is absorbed in a counter

current flow of cool mineral oil. The non condensable gases from the top of this column

will be vented via an ejector. Similar to the existing plant the ejector will be connected to

the marc silo pneumatic lean phase conveying line. Any non recovered hexane will be

vented to the atmosphere from the top of the marc silo.

Non condensible gases

ejected to atmosphere

Steam ejector

To evaporator 2

Steam

Steam

Absorption Stripping

column column

Vapour from hex-steam

condenser

Vapour collected

from all other

vessels Pall

ring

Chilled water in packing

Chilled water out

Steam

injection

Condensed hexane

to hex water separator

Figure 5 Hexane recovery process summary



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The hexane laden oil from the absorption tower is then heated and sent to the top of the

stripping column which is also packed with pall rings. Live steam is injected into the

bottom of the stripping column and this strips out the hexane as a vapour. The steam

and vapour mixture from the top is sent to evaporator 2 (Figure 4) where the heat is

used to evaporate hexane. The hexane is subsequently recovered.

The hot oil from the base of the stripping column is then cooled and recirculated back to

the absorption column. To minimise heat losses, heat is transferred from the hot to the

cold oil as they are pumped from the columns using an oil to oil heat exchanger.

2.1.1.6. Recovery of hexane from spent marc

Hexane used in the extraction can be adsorbed into the spent marc. This will be

recovered by heating the marc in a “toaster” using steam. The toaster will consist of

screws mounted inside an insulated housing to contain the hexane vapour. Live steam

will be injected into the toaster at the outlet end to flush hexane vapour back and

prevent hexane being lost with the marc. The hexane content of the marc will be

monitored continuously by measuring the hexane vapour content of the storage bin.

2.1.1.7. Handling and disposal of marc

The ‘desolventised’ marc from the toaster will be sent by a lean phase pneumatic

conveying system to a storage silo. Any marc with a high hexane content will be

diverted to a small, separate bin via a belt conveyor. The hexane content will be

reduced to normal levels by allowing it to stand in the bin and also by blowing air into

the bin.

Marc from the silo will be dumped into trucks for land disposal on farms in the vicinity. It

is hoped to be able to briquette some of the marc for sale as a (greenhouse neutral)

fuel. However, this process depends on being able to establish a market for the

briquettes.

2.1.2 Services

2.1.2.1. Boiler

This will be a new package boiler producing saturated steam at 10 bar (gauge). It will

be rated at 2MW or 3200 kg/hr of steam, and will be designed for unattended operation.

Gas will be used for ignition. The boiler will use the by-product raffinate as the fuel,

although it is expected that up to 20% addition of heating oil may be required. The

raffinate:oil mixture will be stored in two agitated tanks, with a heater installed in the

second tank. Both tanks already exist, and are bunded. To ensure that the raffinate is

completely burnt, a rotary cup burner will be installed. This is necessary as the raffinate

is quite viscous, and also contains a small amount of suspended solids.

Design of the final boiler stack configuration and pollution control equipment will be

subject to the results of modelling boiler stack emissions to meet EPA and stakeholder

expectations. The base design will be configured to allow the upgrade of pollution



Page 15

mitigation measures (cyclones, scrubbers etc) should post commissioning testing fail to

achieve the desired level of emissions predicted by modelling described in this report.

2.1.2.2. Cooling water supply

An additional cooling tower will be installed on the roof of the extraction building that will

supply cooling water to the hexane condenser (main load), hex-steam condenser

(smaller load), oil cooler for hexane vapour absorption column (tiny load). Chemical

dosing and testing for legionnaires will be carried out by third parties including

Legionella every 3 months and Total Cell Count (TCC) performed monthly.

2.1.2.3. Liquid effluent treatment

The effluent treatment system (ETS) is designed to minimise water usage and to trap

hexane spills. Most of the water going to the system will be water from the hexane –

water separator (Figure 6).

This water is contaminated with a small amount of organic material, including organic

acids, and will have a pH of about 5. The hexane will be trapped in the ETS by a series

of baffles and sumps. The basis for this is that the density of hexane is 0.66 versus 1.0

for water, and the solubility of hexane in water is extremely small.

The hexane trap will be sized to contain the contents of the single largest vessel

containing hexane. From the trap, the water will be pumped to a small holding tank. It

will be pumped to the cooling tower to supply part of the make up water demand.

The only water planned to be routinely sent to sewer is the boiler water blow down and

cooling tower purge.

LIQUID EFFLUENT TREATMENT

Water from the Storage tank

hex water separator

From wash Hexane trap

down hoses

Other (minor)

To cooling tower make up water

Coarse

Floor drains strainer

Settled solids 'sump'

Potential hexane trapped here

Figure 6 Effluent treatment plant

2.1.2.4. Site access and transport

Delivery of harvested vegetable material to the Ulverstone site is via the main arterial

highway routes from harvesting areas mainly in the north of the state and in the

Ulverstone - Devonport hinterland. The majority of the cartage activity is concentrated

between the months of December to March and uses the nearby Bass Highway as the



Page 16

main access route. Site access along Industrial Drive will not change. A second point of

access is available off Export Drive and will only be used for emergency egress and

construction activities. An increase in truck movements from 16 up to 27 trucks per day

is forecast during increased supply of raw materials during harvesting (See Section

3.6).

2.1.3 Project implementation

Subject to external EPA and Council approvals the project will require internal

commercial approval. Once external and internal approvals are completed the project is

expected to be completed within 18 months. Commissioning of the plant for the

processing season of 2011-2012 is desirable.

2.2 Project area

2.2.1 Geomorphology

The location of Botanical Resources manufacturing site is at the eastern end of the

Industrial Drive. The site is approximately 500 m from the foreshore and approximately

3.5 km from the centre of Ulverstone (Figure 1).

In this vicinity the coastal plain adjacent to Bass Strait varies in width from several

kilometres, where rivers enter Bass Strait, to zero where mountain ranges reach the

coast and form headlands and offshore reefs. Elevated hinterland located to the south

of the site is largely Tertiary dolerite with sequences of Precambrian quartz wacke. The

processing plant area is comprised of Holocene alluvium containing sand and quartzite

derived pebbles and gravels.

Test and foundation holes have revealed that the upper 0.1 m consists of brown gravel

possibly imported, from 0.1 to 0.5 m black organic rich sand, from 0.5 to 1.8 m black

clayey sand and from 1.8 to 2.0 m brown to light grey clayey sand becoming lighter in

colour with depth. At some foundation test holes the presence of small rounded floaters

and compacted 'coffee rock' was noted.

2.2.2 Hydrology

The site lies on relatively level coastal alluvial deposits derived from surrounding

Tertiary coastal material. The water table at the site is encountered at approximately 0.9

m below the current natural ground surface during winter months above a relatively

compacted clayey sand layer. The upper layers of the sand (down to approximately 2m)

are relatively porous.

The nearest groundwater bore lies 400m to the south and up gradient at the property of

'Westella', others are located further east at Turners Beach and Leith. Groundwater

quality is variable with higher salinity and conductivity values reported within bores

closer to the coast. Most bores are only pumped during periods of dry weather and the

water used for irrigation purposes.



Page 17

Storm water from the site currently flows into roadside concrete gutters to the south and

west. The remainder currently flows to the north over farmland, and then to a series of

excavated drainage/soakage channels adjacent to the railway line. From there the

surface and subsurface groundwater flows under the railway line into Bass Strait.

2.2.3 Flora

The processing plant area consists of landforms that have been extensively modified by

leveling, and the planting of imported grass species. There is virtually no native flora in

the immediate vicinity of the site. The adjacent areas have also been highly disturbed

by clearing and farming activities.

2.2.4 Fauna

The vegetation clearing that has occurred within the past one and a half centuries has

also significantly altered the fauna of the area. Remnants of the tea tree contain small

birds including wrens, honeyeaters, whistlers and thrushes, with the open areas of

bushland on the steeper hillsides and patches of remnant forest being inhabited by

potoroos, wallabies, tiger snakes, kookaburras, black cockatoos, wattle birds and forest

ravens. Wading birds including the grey heron frequent the shallow more open

stretches of the river estuaries along with the silver gull, pacific gull and oystercatchers.

A search conducted on the Parks and Wildlife Threatened Species Database indicated

that there were no recorded threatened species within the immediate vicinity of the

plant however the grey goshawk, the vulnerable swift parrot and a rare orchid were

listed along the coast for the former, and in the upper reaches of the valleys to the

south west and south east for the latter two.

2.2.5 Site history and land use

The 4.63ha site is on land that was originally used for grazing cattle and then for

furniture construction by Pipers. Development of the site by BRA has been being

undertaken in two phases.

The initial phase occurred in 1998 with the transfer and expansion of the existing

laboratory and administration functions from 113-115 Eastlands Drive to 44 Industrial

Drive. At the same time the pelletising plant was expanded and transferred from

Tonganah. Council building and environmental approval for a Stage 1 processing was

obtained in August 1998.

Approval for level 2 operations on the site was granted with the issue of a Permit by the

Central Coast Council in December 2000. The Environmental Permit conditions were

issued on 17 November 2000.

The main area of the site is occupied by storage sheds, pelletiser plant, refinery,

extraction and laboratory. All processing and service sheds are galvanised iron clad,

the major office and laboratory accommodation are brick buildings. The extraction plant



Page 18

is constructed of structural steel under a galvanised iron roof with no side walls. A wire

security fence surrounds the site and along some sections this is electrified.

2.2.6 Surrounding land use

The surrounding land has historically been used for raising of dairy cattle. Over recent

years with the eastward growth of the Ulverstone light industrial area, the Central Coast

Council purchased a section of the farmland as part of the extension plans for Industrial

Drive, and in 1998 rezoned the land as Industrial (IB) - General.

The adjacent land use and surrounding zoning is presented in Figure 11. Activities

within a 300 m radius of the plant include;

− Engineering workshops

− Industrial and agricultural equipment sales and servicing

− Bakery

− Asphalt manufacturing and supply

− Concrete block manufacturing

− Bass Highway

− Residential and B&B accommodation (Westella, ~250 m to the south)

− Cattle grazing

In addition activities within 500 m of the plant include;

− Low density residential (nearest residence 450 m to the south on hill crest)

− Residential (nearest residence 400 m to the north on coastal plain)

− Public open space areas on the foreshore north of the railway line

The East Ulverstone Industrial Estate is recognised in the Central Council Planning

Scheme as one of three areas where industrial use and development will be focused.

The Planning Scheme includes provision for the operation of the chemical extraction

plant and boiler within the Industrial Zone.

Long term Council plans are for the immediate area to continue to be developed as

industrial and mixed light industrial / commercial business in conformity with the

planning scheme and any subsequent amendments. The purpose of the Industrial Zone

is to provide for manufacturing, processing, repair, storage and distribution of goods

and materials where there may be off-site impacts that affect the amenity of other uses.

Resource processing activities are a discretionary use in the Industrial Zone which

means they are subject to a public process as set out in Section 57 of the Land Use

Planning and Approvals Act 1993.



Page 19

Figure 7 Botanical Resources Australia manufacturing plant land use and zoning plan (buffer distances from boiler stack)



Page 20

3.0 Potential Environmental Effects

3.1 Air emissions

3.1.1 Air Quality Goals and Standards

The applicable air quality standards are set by the Tasmanian Government under the

Environment Protection Policy (Air Quality) (DPIWE 2004) and the National

Environment Protection Measure for ambient air quality (air NEPM) (NEPC 2003). The

standards used in this report are summarized below in Table 1.

Table 1 Relevant Environment Protection Policy (Air Quality) and air NEPM air quality guidelines

Pollutant Averaging Period

Unit EPP (Air Quality) air NEPM

Nitrogen dioxide 1 hr µg/m3 328 246

Particles as PM10 24 hr µg/m3 150 50

n- Hexane 3 min mg/m3 6 Na

3.1.2 Stack testing

Monitoring of boiler stack emissions was completed on the 29th of March 2010 under

continuous processing operations using a fuel mixture of 80% raffinate with 20% fuel

oil. The results of testing are summarized in Table 2. The full results of stack test used

in modeling are presented in Appendix 2.

Table 2 Existing boiler in-stack monitoring results

Parameter In stack

EPA limit

Test Result

Normalised 7% O2

Unit of Measure

Average velocity 10.2 m/sec

Average stack temperature 269 °C

Average oxygen 14.3 %

Average carbon dioxide 5.02 %

Particulate matter Concentration 100 106 221 mg/Nm3

Particulate matter Emission rate 3.71 g/min

Oxides of nitrogen (as NO2) Concentration 500 127 265 mg/Nm3

Oxides of nitrogen (as NO2) Emission rate 4.45 g/min

TVOC expressed as n-hexane Concentration na 43.1 mg/Nm3

TVOC expressed as n-hexane Emission rate 1.57 g/min

3.1.3 Boiler stack particulate and NOx emissions

3.1.3.1. Previous emissions models

Initial models of particulate emissions from the existing boiler were based on

engineering design criteria for a 1 MW heat output boiler with a fuel consumption of 120



Page 21

kg/hour that would provide sufficient energy for a 75 tonne per day (~3 tph) extraction

plant. NOx emissions modeling has not previously been undertaken at BRA. Building

wake effects were included in the modeling calculations to allow for down wash effects

from the nearby storage sheds.

Modeling was also completed for a 40% raffinate and 60% fuel oil mix, whereas current

fuel mix is 80% raffinate and 20% fuel oil. The reduction in use of fuel (maximum sulfur

content of 0.5 percent by weight) will result in a reduction of potential sulfur emissions

because raffinate has a sulfur value of 0.09%. Typical composition of the raffinate is

summarised below in Table 3.

Table 3 Composition of Pyrethrum Raffinate

Component Range (Wt %)

Vegetable Oils 40-60

Free Fatty Acids 15-20

Sesamin 2-5

Amyrin/Taraxasterol 1-4

High MW Alkanes 3-7

Pyrethrins 0.3-0.4

Carotenoids 0.3

Ash 0.35 -0.62

Sulfur 0.09

Particulate emission rates were based on an in stack concentration of 50 mg/m3 and

flow of 0.54 m3/sec. The modeling calculations showed that an increase of up to 1.9

µg/m3 occurs for PM10 concentrations in the vicinity of the emission point under worst

case conditions over 24 hour averaging time periods. The model confirmed that

changes in total suspended particulate concentrations are not likely to be detected

above the average background levels at the nearest private residence 300 m away.

3.1.3.2. Updated boiler stack particulate emission and NOx model

Modeling of possible boiler stack emissions for the proposed new facility was

undertaken using new information and models. The results of modeling are presented

in detail in Appendix 3. The critical improvements to the emission model included;

− Use of TAPM to produce m ore accurate and refined dispersion models that

included updated site infrastructure.

− Use of actual stack test monitoring data collected in March 2010 that had

particulate concentration of 106 mg/Nm3 while using a raffinate to fuel ration of

80:20.

− Particulate and NOx mass emission rate scaled by fuel consumption, which is

set to reflect operations at 4.5 tph and 170 kg/h fuel consumption.



Page 22

− Assuming that all (100%) of measured particulate emissions are PM10.

− Assuming a 27 m high stack.

− Assuming that both boilers (existing and new) would be operating at the same

time.

Results of particulate emissions modeling (Figure 8) indicate that using a 27 m high

stack, and assuming a background of 15 µg/m3, the maximum offsite PM10

concentrations are ~45 µg/m3 (24 hr). This value is within air NEPM requirements of 50

µg/m3 (24 hr) and well below Environment Protection Policy (Air Quality) design ground

level concentrations (DGLC) of 150 µg/m3 (24 hr).

Under the equivalent scenario (using a 27 m high stack) the results of NOx emissions

modeling indicated that the maximum predicted GLC is 96 µg/m3 (1 hr). Assuming a

background concentration of approximately 10 µg/m3 the resultant concentrations are

well below the Environment Protection Policy (Air Quality) DGLC of 328 µg/m3 (1 hr).

The results of far field modeling also indicate that particulate and NOx emissions rapidly

dissipate with distance from the stack. The worst case likely effect at the nearest

residence (Westella) of potential particulate emissions is approximately +5 µg/m3 (24

hr), and at distances of approximately 500 m the effect is negligible.

3.1.3.3. Potential impacts of boiler stack particulate and NOx emissions and

their mitigation

The results of modeling indicate that under worst case conditions a 27 m high stack

provides a suitable mechanism for the dispersion of air emissions in line with the

Environment Protection Policy (Air Quality) maximum design GLCs.

Additional contingencies will be included in the design of the new boiler and its

operation to ensure that the ability to implement additional pollution mitigation measures

if required. These measures include;

− Confirmatory stack tests of the existing boiler performance to be undertaken

during 2011.

− Post commissioning stack testing of the new boiler to confirm model inputs.

− Ability to implement additional purification and treatment of the raffinate fuel

source to reduce ash component.

− Based on the results of pre and post commissioning stack test results, if

required supported by emissions models, implement appropriate pollution

control devices in liaison with the EPA.

− Installation of Continuous Emissions Monitoring System (CEMS) pollution

monitoring equipment to continuously monitor stack emissions if required.



Page 23

The construction of an asphalt plant on the adjacent property on the southern boundary

has also been taken into account in air quality predictions. Based on the information

provided by GHD (2008b) the PM10 GLCs will be under EPA Air Quality design criteria

of 150 µg/m3 (24 h). Details of this assessment are described in Appendix 3.

Figure 8 TAPM highest predicted PM10 GLCs (24h) from a 27m high stack not

including background (NEPM limit of 50µmg/m3)

3.1.4 Hexane emission modeling

3.1.4.1. Previous models of hexane emissions

Approval of the existing plant was based on hexane emission models that assumed an

overall loss of 15 L/t of processed pellets. The loss model assumed 50% of the lost

hexane was emitted via the hexane vapour recovery system. The other 50% was lost to

marc. Of the 50% lost to marc 50% was considered to be emitted to atmosphere from

the marc silo and the residual 50% would be progressively emitted to atmosphere over

a period of weeks to months. Hexane emissions were modeled to be emitted from a

single source hexane vent from a stack located 3m above the marc silo.



Page 24

The results of the modeling indicated the 1 hour average concentration of hexane in the

atmosphere is contained within the BRA industrial boundary area at the 1 mg/m3

contour line. The modeling also predicted an increase of up to 1.1 mg/m3 occurs in the

immediate vicinity of the emission point under worst case conditions over a 3 minute

averaging time period. The 3 minute time average predicted concentration was less

than the Environment Protection Policy (Air Quality) design ground level concentrations

for n-hexane of 6 mg/m3. The results indicated that the hexane emissions were not

likely to present an odour or health risk to workers in adjacent industrial areas or to

occupiers of Westella or other private residences and schools to the west.

3.1.4.2. Updated hexane loss model

Emissions of hexane from the plant represent a significant loss to plant operating

efficiencies as well as health, safety and environmental risks. As a consequence of this

hexane usage, recovery and losses are monitored continuously, with the information

used to update and modify plant performance.

The processes used to recover hexane and prevent operational losses are outlined in

Section 2.1.1.5. The annual loss rate of hexane is well defined by annual reconciliation

of stocks and purchases. The annual loss rate of hexane of the plant for the last 6 years

is described in Table 4.

Table 4 Summary of annual hexane losses

Year Hexane Loss Rate

(L/t pellets processed) Description

2010 4.7 Smaller pellets implemented retaining less hexane and combined with improved absorber operation.

2009 7.4 Adjusted steam distribution to desolventising system.

2008 7.7 Implementation of continuous feed to desolventising system and new clarifier.

2007 21.7 Poor quality pellets and large amount of sludge containing hexane from clarifier exacerbating losses

2006 12.6 Reconfiguration of plant equipment

2005 20.0 Data not recorded prior to 2005

Due to ongoing improvements in operating practices and recovery systems hexane loss

rate is now ~4.5 L/t of processed materials. This improvement along with routine plant

measurements and periodic monitoring has also resulted in reassessment and

improvement of hexane loss models. Critical changes include;

− Measurement of residual hexane in the marc has identified that very little

hexane is exported offsite in the marc.



Page 25

− Periodic measurement of hexane in the adsorption column emissions has failed

to detect significant concentrations.

As a consequence losses are now considered more likely related to diffuse losses from

the plant area during operation. These losses can be created by events such as partial

failure of seals on operating equipment or plant startup and shut down created by

periodic maintenance or process interruptions.

A new loss model has been used for the purposes of assessing hexane emissions. The

losses associated with operating the plant are described in Table 5. The most

significant changes relative to previous models are the overall loss rate of hexane

modeled is 4.5 L/t, and the majority of the hexane is lost from diffuse operational losses

from the extraction plant during operation.

Table 5 Hexane losses at 4.5 tph processing (~20.25 L/h emissions)

Source % Days Comment

Fugitive losses 5.0 365 Storage tank and other storage/transfer losses during whole year.

Diffuse operational losses 75.0 150 Losses due to extraction plant operation and maintenance events from both extraction facilities pro rata of throughput.

Loss via hexane scrubbers 5.0 150 Hexane passing through scrubbers and sent to marc silo with marc.

Marc on site 10.0 150 Hexane released from marc held in silo.

Marc exported off site 5.0 150 Decays over period of days to months off site.

3.1.4.3. Updated hexane emission model

New models of potential hexane emissions have been generated using the improved

understanding of hexane losses. The results of modeling are presented in Appendix 3

and are summarized in Figure 9. The improvements to models include;

− Use of TAPM to produce more accurate and refined dispersion models that

included updated site infrastructure.

− Use of actual boiler stack test monitoring data collected in March 2010.

− Hexane loss rate scaled by processing rate, which was set to reflect current

performance at 4.5 L/t at a combined plant throughput rate of 4.5tph.

− Assuming the majority (75%) of losses occur as diffuse losses operation of the

plant over 150 days of the year from both the existing and new extraction

plants.

Overall an increase in production rate at current hexane losses will result in increased

hexane losses from 168 L/hr to 486 L/hr under maximum throughput rates. The results

of emissions modeling presented in Appendix 3 indicate that the increased loss rate of



Page 26

hexane result in maximum offsite concentrations 2.6 mg/m3 (3 min). This concentration

does not exceed the Environment Protection Policy (Air Quality) design GLC of <6

mg/m3 (3 min average).

Figure 9 TAPM highest predicted Hexane GLCs (3min) (NEPM limit of 6 mg/m3)

3.1.4.4. Potential impacts of hexane emissions and their mitigation

Control of hexane and reduction of hexane emissions is critical for the safe and

sustainable operation of the plant. A range of controls have been implemented to

ensure that hexane emissions are minimized. These measures include;

− Processing vessels either sealed or operating under vacuum.

− Hexane recovery process that includes chilled water condensers, oil stripper,

and a toaster that significantly reduce the loading of residual hexane in the

marc.

− Venting of any captured non recoverable hexane via the marc silo.

− The design of the plant (open front) will prevent build up of hexane in the plant

area and ensure the rapid dispersion of hexane from the vicinity of the plant.



Page 27

− Post commissioning vent point hexane monitoring to confirm emission model

inputs reported to EPA. Vent point monitoring locations include – existing boiler

stack, new boiler stack, existing adsorption column exhaust, new plant

adsorption column exhaust, marc silo vent stack

− The plant area will be monitored continuously for hexane losses by LEL

monitors and sensors. Sensors will be permanently installed in the area of the

extraction plant.

− Ongoing assessment and reporting of annual losses as well as testing loss

model assumption by additional monitoring during 2011 of diffuse and

controlled plant losses.

− Operation of the site in compliance as a Large Dangerous Substance Location

(see section 3.7).

The modeled worst case GLCs (Figure 9) indicate that concentrations of hexane in the

vicinity of the plant will be significantly below occupational exposure standards of 180

mg/m3 (8h TWA). The results also indicate that concentrations of hexane dissipate

rapidly at distance from the plant with a maximum offsite GLC of 2.6 mg/m3 (3 min).

Combined with a high odour threshold of 210 mg/m3 any fugitive hexane emissions are

unlikely to have any offsite measurable or detectable impacts.

3.2 Rivers creeks wetlands and estuaries

All surface areas subject to the possibility of contaminated water exposure or hexane

spillage are sealed and bunded to minimise the likelihood of surface or groundwater

contamination (Figure 10). All stormwater that could potentially be contaminated from

processing operations will be contained on hard surfaces and directed to the effluent

treatment system. All clean stormwater will discharge via a storm water drain that

reports to a soakage area and tea tree clump adjacent to the railway line some 300m

northeast of the BRA block and approximately 80 m from the coast.

Rainwater from the roof will be diverted to a storage tank and this will be used for the

wash down hose. Surplus roof storm water and clean storm water is discharged via

storm water drains to the east and north of the premises.

Pyrethrins have a 96 hour LC50 concentration in water of 3-50 ppb for certain fish

species. Decomposition of any residual pyrethrin would rapidly occur and therefore it is

considered highly unlikely any materials will reach the coast and have any measurable

environmental impacts. The leakage of a substantial quantity of pyrethrin concentrate

crop or marc into the local storm water system is not considered likely.



Page 28

Figure 10 Site storm water plan.



Page 29

3.3 Liquid effluent

It is proposed to recycle up to 63% of all process waters. The residual 37% will be

treated and released to sewage (Table 6).

Water discharged to sewer will be the cooling tower bleed water and boiler blow down

water. The effluent being disposed of to sewer will have a maximum TSS of <200 mg/L,

COD <1500 mg/L and BOD <600 mg/L.

A standalone hexane trap will be constructed for the new extraction plant. Effluent

waters (any water that potentially contain solids and/or hexane) will be sent to the

hexane trap located at the rear of extraction facility (Figure 3). The trap will be sized to

contain the hexane in the largest single vessel plus 50% safety margin. It will also be

used to assist settlement of suspended solids.

Other effluents from the proposed plant will be used for cooling tower makeup water.

These effluents will not contain hexane or any appreciable amount of suspended solids.

These include; cooling tower overflow and cooling tower bleed (2.3 m3/day).

A single fire water holding pond will be constructed and sized to service both the

existing and new plants.

Table 6 Summary of typical effluent sources

Total Use Recycled

Source (m3/day) %

Water from hexane water separator 12.9 95

Overflow from the hot water tank 1.9 95

Wash down water from the plan 1.5 95

Storm water (10 mm rain) 5.0 95

Hexane or miscella spills 0.0 0

Cooling tower bleed 4.3 0

Boiler blow down 6.5 0

Total 32.1

Process water discharge 11.9 (37)

Process water recycled 20.2 63

3.4 Solid wastes

Increased generation of non recyclable waste materials is unlikely to be significant.

Solid rejects and waste generated on site consist of;

Reject solids (mainly grit) from sediment traps (<< 5 tpa)

Reject solids, wastes and grit from sediment traps is mixed with the marc for removal

off-site. This is undertaken by licensed contractors and disposed of at appropriate

facilities.



Page 30

Marc (14,000 tpa)

BRA is currently exploring the opportunity to sell marc as fuel briquettes. If these

briquettes are used to replace coal there is a potentially large benefit as e.g. 8,000

tonne of marc will be able to replace about 5,000+ tonnes of coal.

The marc dryer selected will dry the marc using indirect steam. This will reduce the

amount of moisture in the marc, which in turn will make it easier to briquette. Any

unsold marc will be disposed of by spreading it on farm land remote from water courses

(as is done at present).

Trace quantities of ash (< 5 tpa)

Only trace amounts of ash are likely to be formed as a result of the combustion of the

raffinate and fuel oil. Ash is removed by the licensed waste removal contractor.

Other waste (<10 tpa)

Miscellaneous packaging is transported to the local Council waste disposal site, and a

licensed waste removal contractor collects any miscellaneous liquid wastes from pits.

3.5 Noise emissions

The nearest residential premises to the site is the Westella House heritage property

Bed and Breakfast. The property is located on the southern side of the Bass Highway,

approximately 250 m from the proposed development site.

Noise measurements at the BRA site boundary collected in March to April 2008 by

GHD (2008a) indicate background noise (LA90) to range from 40-50 dB(A) at night to 50-

60 dB(A) during the day. GHD (2008) also determined that background noise at a

residence 300m to the south of the site ranged from 30-40 dB(A) at night to 50-60

dB(A) during the day.

Other than noise generated through increased truck movements during harvest period

noise generated on the site is not expected to significantly increase due to increased

throughput rates.

Noise sources on site include;

− truck, forklift and vehicle movements including the statutory reversing signal

− emissions from the crop aeration system

− emissions from the hammer mill used for size reduction prior to the pelletiser.

− background noise generated as a result of electric motors, conveyor belt

operation, dust extraction fans and boiler operations.

Noise emissions are minimised by facing any directional outlets such as the aeration

fans away from the nearest residences and the use of 'intelligent reversing sirens' on

mobile equipment that provides a warning signal only 5 dB above the ambient noise



Page 31

levels. Telephone ringing noise within the operational areas are minimised by using

visual light indicators rather than an intrusive loud sound. The hammermill is enclosed

within an effective noise reduction structure within the pelletiser building to reduce

emissions.

Noise due to extra truck movements is confined to a short period of up to 6 weeks

during crop harvesting. All unloading of vehicles occurs undercover. This activity has

been operational for 6 years at the site with no complaints from neighbours.

During construction it is proposed that the DECC (2009) interim construction noise

guidelines be used. These guidelines advocate a LAeq (15min) rating background level +

10 dB(A) as a guide. Construction activities will only occur during daylight hours.

3.6 Transport impacts

Impacts to transport are likely to occur during construction of the plant and then due to

an expected maximum 83% increase in production throughput that will result in

increased truck movements.

The harvest period timing and duration is determined by weather conditions, and

typically corresponds to late summer. The harvest period is typically 35 days long.

During the harvest period increased truck movements will occur along Industrial Drive.

Assuming a 35 day harvest period, 8 tonnes per load and a total of 8,200 tonnes

processed material the current (2010) number of trucks per day during harvesting is 29.

By maintaining the harvesting window at 35 days and assuming 15,000 tonnes

processed (equivalent to 7tph treatment rate) the total number of trucks is 54. This is

expected to increase the total number of trucks accessing the site during peak harvest

period from 32 to 60 (Table 7). The added impact of deliveries and the cartage

represent a very minor addition (<1%) to road traffic numbers in the Ulverstone area

(Table 8).

Impacts of increased traffic flows are therefore likely to be isolated to Industrial Drive for

a period of 35 days each year. The timing of the harvest period will coincide with good

weather and long daylight hours mitigating against road traffic hazards. Unloading can

continue into the late evening and to mitigate noise emissions during unloading all

unloading occurs undercover. To reduce the risk of congestion the site has also

increased the rate of truck unloading by installing an additional weighbridge.

During construction site access along Industrial Drive will not change. Increased traffic

will occur due to the access to the site by contractors during construction. This effect

will be temporary (1-3 months) and is not considered a significant change given the

industrial land use zoning. During construction access will also be provided off Export

Drive to limit risk of traffic congestion along Industrial Drive.



Page 32

Table 7 Predicted peak harvest truck movements of raw materials, residue and products

Stage Materials & residue

Current

8,200tpa

Truck/day

Upgrade

15,000tpa

Truck/day

Destination

Delivery Raw material 29 54 Drying or Crop Storage Shed

Extraction Marc 3 5 Farmers, Nurseries

Dispatch Product 0.15 0.5 Customer

General Waste Plastic, wire, office waste 0.15 0.5 Contracted waste disposal site

Total 32 60

Table 8 Bass Highway Traffic Counts*

Location East of Leven River Bridge

BRA current contribution

BRA future contribution

Total Vehicles/Day 10,010

Number of Trucks 871 32 60

% 8.7 0.32 % 0.60 %

(*Information from Traffic Management Section Dept of Infrastructure Energy and

Resources)

3.7 Dangerous goods and chemicals

The site has formally notified of its status as a Large Dangerous Substance Location

(LDSL) in 2009 due to the presence of significant quantities of Hexanes and pyrethrin

products. The site is operated in accordance with WST (2009) guidelines. This includes

implementation of a range of risk mitigation measures and controls including, safe

handling and storage systems, employee and visitor training, suitable signage and

demarcation of hazardous substances, preparation of emergency response plans and

training as well as periodic assessment of risks.

BRA maintains an emergency fire crew on site. During extraction operation the crew is

manned from within the workforce on a 24 hour per day basis whilst processing

operations are being conducted. This crew is well equipped and trained to cope with

emergencies, such as fires and spills involving hazardous substances that may occur

on the site. Emergency action plans (SOPS) have been established for those

emergency scenarios considered to possess the highest potential.

Hazardous operations procedures and scenarios have been examined in conjunction

with onsite and offsite emergency personnel. Contingency plans have been developed

in conjunction with local emergency groups that detail actions to be taken in the event

of a significant incident such as that described below. These were developed during the



Page 33

construction phase and follow up action initiated so that on site familiarity is provided to

backup emergency personnel

The proposed upgrade will result in higher rates of consumption and production of

chemicals and other hazardous substances. Increases in the stored amount of

dangerous goods will only occur for Hexane and pyrethrin products. The total amount of

material stored on site is summarized in Table 9.

3.7.1 Hexane storage

Hexane is stored in three 50 kL above ground tanks. An additional 50 kL storage tank

will be constructed as part of the new extraction plant. The storage tanks are protected

by concrete bunding 15 x 15 x 0.6 m high designed to contain the entire tank contents

in the event of a catastrophic multiple tank failure. A spill contained within the bund (and

not on fire) would be recovered. A wind sock provides wind strength and direction

information so that any evacuation of personnel can be undertaken in the upwind

direction. Emergency access and egress is to be available from the rear of the property

via Export Drive.

Table 9 Summary of BRA Dangerous Goods inventory changes Material Previous Quantity Stored Planned quantity

Hexane 120 kL in 3 x tanks 160 kL in 4 x tanks

Pyrethrum 10,000 t in sheds 15,000 t in sheds

Diesel Fuel 1,000 L Overhead Tank 1000 L overhead tank

Lubricating Oil 2 X 205 L Steel Drums 2 X 205 L Steel Drums

Fuel Oil (80-90% raffinate) Boiler fuel Tank 50 kL Boiler fuel Tank 50 kL

Biocide 1 X 25 L Plastic Container 1 X 25 L Plastic Container

Lab Solvents 12 x 20 L Steel Drums 12 x 20 L Steel Drums

Boiler Corrosion Inhibitor 2 X 25 L Plastic Drums 2 X 25 L Plastic Drums

Boiler Floc Treatment 2 X 25 L Plastic Drums 2 X 25 L Plastic Drums

Boiler Treatment Dispersant 2 X 25 L Plastic Drums 2 X 25 L Plastic Drums

Boiler Treatment Alkali 2 X 25 L Plastic Drums 2 X 25 L Plastic Drums

Raffinate 20 tonnes max in 220 L drums and SS tank

20 tonnes max in 220 L drums and SS tank

Pyrethrin Oleoresin 100 Drums (max) 100 Drums (max)

Piperonyl butoxide 4 x 200kg drums 4 x 200 kg drums

Paraffinic oil 15 tonnes in 200 kg drums 15 tonnes in 200 kg drums

Vegetable oil 16 tonnes in 200 kg drums 16 tonnes in 200 kg drums

Butylated hydroxy toluene 8 tonnes in 20 kg bags. 8 tonnes in 20 kg bags.

3.7.2 Storage of compressed and liquefied gases

On site cylinder storage occurs with most gases being supplied on demand from the

local supplier in specially designed cylinder cages. Individual gas cylinders are kept in a



Page 34

series of concrete and brick compounds in the stores yard. LPG gas is delivered and

stored on site in a 190 kg cylinder.

The only gas stored in bulk is liquefied carbon dioxide which is stored in an approved

pressure vessel at -25°C and 19 Bar. Carbon dioxide is used inside the refinery at the

rate of ~500 kg/day. Gas from this source is also used for flushing of the extract plant

before the start of operation or at the end of extraction to reduce the risk of creating a

transient flammable atmosphere inside.

3.7.3 Storage of other chemicals

A bunded storage area is provided at the back of the existing refinery building and in

the adjacent cool store for 70 T combustible liquid of the type: oleoresin, PY-T-50, Vista

LPA, Vegetable oil, PBO (piperonyl butoxide), ethylene glycol and lubricating oils. BHT

(butylated hydroxy toluene) is a combustible solid and is also stored there. This store is

provided with a 6m free surround and firewalls where a free 6m distance could not be

maintained. The risk of a spill is low and containment would be relatively easy with the

ready availability of soakage and spill collection booms.

Fuels are separated from oxidants and corrosives, being stored in a separate room.

The quantity of materials held is small to lower the danger potential. Even a total spill

involving all of the stored goods would be contained within the building. The chance of a

fire is small due to the separation of flammables and oxidants, and it would be attended

immediately by the site emergency crew.

Chemicals are also stored on spill containment pallets in either the Stores Compound,

or at the point of use on the site (water cooling towers and boiler). The likelihood of

leakage is considered remote given the majority of surfaces are covered and all

drainage reports to an effluent treatment plant.

3.7.4 Pyrethrum crop

Pyrethrum crop and pellets are combustible. To reduce the likelihood of the crop or

pellets generating heat an aeration system that assists in controlling temperatures are

used in the crop and Pellet sheds. Heat sensors connected to a site alarm system are

provided in crop and pellet storage sheds. This crop material would spoil if sprayed with

water and for that reason a flood fire system has not been provided.

3.8 Fire risks

Fire risks at the facility are considered to be significant and a systematic approach to

their management has been adopted. External advice has been sought from R4Risk

Pty Ltd for the planned design of the fire fighting system, and the plant layout. A copy of

the report is presented in Appendix 4.

The R4Risk assessment has been undertaken assuming the plant was operating at 7.5

tph. The assessment therefore contains a level of redundancy given maximum planned

throughput rates are now 4.5 tph.



Page 35

As a consequence of the assessment a 15 m exclusion zone is maintained around the

new and existing extraction plant, boiler, crop and pellet storage and pelletiser plant for

protection of neighbouring activity and access. The proposed plant layout allows

adequate spacing and access for fire fighting.

External advice on fire fighting system has been received and systems will be upgraded

as follows:

− A new pumping system will be installed consisting of one diesel and one

electric pump, plus a jacking pump. The existing pumping system for the

current plant will be removed.

− A new 150 mm diameter line will be run from the new pumps to the foam

sprinkler system for the new plant, plus the new fire hydrants. This line will also

supply the foam sprinkler system for the existing plant.

− The existing 100 mm diameter fire mains system will be retained for all the

existing hydrants. As noted above, it will not supply the new pumping system.

− To comply with the building code a single fire water sump will be installed to

contain the run off from fire fighting water. The sump will service both the new

and existing plants.

3.9 Health risks

Emissions to atmosphere from the processing plant consist of dust and gases from the

boiler stack and residual particulate organic material as well as minor odours from the

use of hexane and from the pelletiser. The health implications of the above emissions

are confined to the immediate vicinity of the discharge points as confirmed by the

modeling and an Environmental Health Impact Assessment (EHIA) that was undertaken

as a prerequisite for the construction of the existing extraction plant and boiler.

The land use planning designation of the area, and the provision of a spatial buffer

around the extraction plant, provide a high safety margin in the event of a single specific

incident as well as continuous low level discharges.

On site exposure to hexane and particulate matter are monitored through the use of

LEL monitors and sensors. Five sensors are permanently installed in the area of the

extraction plant. Hexane is detected only when a malfunction occurs. There are another

three portable LEL monitors to assist with defining air quality in the plant. The open

structure of the plant was intended to allow rapid dissipation of escaped hexane vapour

should a leak occur.

Monitoring programs are conducted to ensure that the exposure levels of workers are

within the relevant Worksafe Australia Standard as required under the Workplace

Health and Safety Act 1995. To assist in maintaining worker safety, protective



Page 36

measures such as the issue of protective clothing, the fitting of noise and dust resistant

cabs on mobile equipment.

Environmental control measures installed as part of the extraction plant construction are

designed to minimise the risk to the wider community and the surrounding ecosystems.

The groups of individuals that are likely to be most at risk at high dust exposure levels

within the general population are the elderly and the very young or, individuals that

have been sensitised through earlier exposure.

A complaint from an individual in this latter category was received in early 2004. Since

this incident BRA has conducted desktop research into dust exposure issues and are

aware of the health impacts, such as composite dermatitis, relevant to this industry

3.10 Site contamination

There have been no studies undertaken to identify historical or current contamination of

soils or ground water. The likelihood of significant contamination from BRA activities is

low because;

The site has hard surfaces, bunding and created and well defined drainage systems.

Products are organic and are either volatile or have the capacity to degrade over time

with exposure to sunlight and oxygen.

3.11 Sustainability and climate change

The contribution to the balance of greenhouse gas emissions from the growing of

pyrethrum and the combustion of raffinate is minimal, as there is effectively no net

increase in carbon dioxide over this cycle. There may overall be some net decrease as

the composting of residual marc allows the increased growth of other plant material.

The combustion of fuel oil and the use of diesel trucks in the delivery of products will

contribute to greenhouse gas emissions.

Estimated total emissions have been calculated in line with DCC (2009a) and are

summarised in Table 10. These emissions represent less than 1% of Tasmanian

emissions (DCC 2009b).

Table 10 Summary of BRA Greenhouse Gas emissions Current Forecast

Source Quantity Emissions Quantity Emissions

Boiler operation* 216 t 128 t 763 t 452 t

Electricity consumption**

1,955,520 kWh

450 t 3,800,736 kWh 874 t

Transport*** 41,000 km 28 t 75,000 km 51 t

Total 606 t kg CO2-e 1377 t kg CO2-e

*Assumes 80:20 raffinate to heating oil, raffinate density of 1 and heating oil density of 0.88, 120 days

operation. Raffinate allocated as other type of biofuel.



Page 37

**Assumes 120 day extraction plant operation and 83% increase in refinery and pelletising power use at

constant demand.

***Assumes 8 t/load and average distance traveled is 40 km and fuel consumption is 25 L/100km.

3.12 Cultural heritage and sites of high public interest

One historic heritage place has previously been identified within the broader vicinity of

the Site. This place, Westella, is located at 68 Westella Drive, on the opposite side of

the Bass Highway, approximately 250 metres to the south east of the proposed new

facility (Figure 7).

Westella is recognized as a place of high public interest. A series of existing roadways

separate the BRA site from Westella, including Industrial Drive and a four lane dual

carriageway highway (Bass Highway). Given the location and separation of the site by a

significant 4 lane highway it is considered unlikely that the proposed plant upgrade will

significantly impact the values attached to Westella.

The provisions of the Aboriginal Relics Act 1975 remain applicable to the proposed

plant upgrade. This Act governs the treatment of Aboriginal relics and protected sites in

Tasmania. It is an offence to destroy, damage, deface, conceal or otherwise interfere

with a relic. Aboriginal cultural heritage is defined under the Act as ‘any place, site or

object made or created by, or bearing the signs of the activities of, the original

inhabitants of Australia or descendants of such inhabitants in or before 1876 in

Tasmania’.

The location of the proposed new facilities is within an operational plant and already

significantly disturbed by historical usage and ongoing usage. The possibility of locating

heritage items is considered unlikely. Should such heritage items be identified during

the course of further development of the site, their presence will be notified to the

appropriate authorities in accordance with the requirements of the Aboriginal Relics Act

1976 and the development halted until appropriate advice is received.

3.13 Visual amenity

The location of the proposed plant is entirely contained within the existing processing

facilities. The only part of the new facility that will be visible from adjacent road ways will

be an additional boiler stack and the roof and upper sides of the extraction plant. The

new facilities are intended to be iron clad and in colours (green – Dulux wilderness or

equivalent) matching the existing facilities. Photographs of the BRA Ulverstone site

taken from local road ways and showing the location of the proposed new facility and

existing facilities are presented in Appendix 1.

3.14 Decommissioning and rehabilitation

Upon announcement of permanent cessation of production on the land, a

Decommissioning and Rehabilitation Plan (DRP) will be submitted for approval to the

Director. The DRP will include all requirements listed in the EPN as a minimum



Page 38

requirement. It will be the responsibility of the Manager of Chemical Processes to

ensure compliance is met.

Upon closure chemical processing equipment would be cleaned and sold and most of

the building structures left for subsequent reuse. The location of the structures in an

industrial zone close to a centre of population would mean a high probability of reuse on

the site. Decontamination of equipment and removal of unused chemicals and additives

would be a relatively straight forward process.

The nature of the materials handled on the site would mean that any residual

contamination in concrete and bunded areas would quickly degrade under the influence

of UV light and atmospheric oxidation. Depending on the projected use for the site,

bunding and tanks would be removed and the areas outside buildings leveled.

A detailed environmental decommissioning and rehabilitation plan would be prepared at

the time of closure to ensure that procedures were detailed in line with planning

requirements from the Central Coast Council at the time.

4.0 Management commitments

The following Table 11 is a summary of the minimum commitment that BRA will

undertake as part of the implementation program for construction, commissioning and

operation of the extraction plant. The item scope includes allowances and

contingencies for additional commitment should it be necessary to meet stakeholder

requirements.

Table 11 Management commitments

No. Item Timing

1.1 Atmospheric Emissions – Particulate and NOx

1.1.1 Based on the results of modeling using the March 2010 stack test results use a 27m high stack for the new boiler.

Design – Underway

1.1.2 Sustain ongoing improvements in the quality of the raffinate fuel to mitigate against particulate emissions.

Design – Underway

1.1.3 Undertake confirmatory stack testing of the existing boiler performance during 2011 (pre commissioning of new boiler).

Pre construction - March 2011

1.1.4 Based on the March 2011 stack test results, and where necessary, update emissions models and review the design of pollution mitigation systems in liaison with the EPA.

Pre construction – May 2011

1.1.5 Undertake post commissioning boiler stack testing of the new boiler and existing boiler (post commissioning).

Post commissioning - January 2012

1.1.6 Based on the outcome of post commissioning stack tests, and if required supported by additional modeling, implement suitable pollution engineering controls to meet the Tasmanian Environmental Protection Policy (Air Quality).

Post commissioning – November 2012



Page 39


No. Item Timing

1.1.7 Investigate Installation of a suitable Continuous Emissions Monitoring System (CEMS) dependent upon the results of post commissioning stack tests and effectiveness of pollution control mitigation strategies.

If required post commissioning – November 2012

1.1.8 Undertake ongoing annual boiler stack emission tests to confirm performance of both boilers and pollution mitigation strategies.

Annual

1.2 Atmospheric Emissions – Hexane

1.2.1 Undertake vent point hexane monitoring to assist improvement of loss models and baseline conditions prior to commissioning. Vent point monitoring locations include – existing boiler stack, existing adsorption column exhaust, marc silo vent stack.

March 2011.

1.2.2 Assessment of suitability for ambient air quality monitoring for VOCs to confirm plant performance

March 2011

1.2.3 Post commissioning vent point hexane monitoring to confirm model inputs reported to EPA. Vent point monitoring locations include – existing boiler stack, new boiler stack, existing adsorption column exhaust, new plant adsorption column exhaust, marc silo vent stack.

Post commissioning

1.2.4 Continuous static workplace hexane LEL monitoring. Ongoing

1.2.5 Annual reporting of hexane losses and updates on activities undertaken to minimise losses, including the results of any monitoring of emissions, coordinated with NPI reporting requirements and submitted to the EPA.

Annual

2.0 Dangerous goods

2.1 Implement WST (2009) guidelines as a Large Dangerous Substance Location

Ongoing

2.2 Sustain safe handling and storage systems, employee and visitor training, suitable signage and demarcation of hazardous substances.

Ongoing

2.3 Periodic review of emergency response plans and training as well as periodic assessment of risks.

Ongoing

3.0 Fire risks

3.1 Upgrade fire management infrastructure as per HAZOP. Prior to commissioning

3.2 Install new pumping system consisting of one diesel and one electric pump, plus a jacking pump.


3.3 Install 150 mm diameter line will be run from the new pumps to the foam sprinkler system for the new plant, plus the new fire hydrants.


3.4 Install a fire water sump to contain run off from fire fighting water.




Page 40


No. Item Timing

4.0 Traffic

4.1 Respond to possible changes in traffic conditions on Industrial Drive and utilize Export Drive where necessary during construction.

As required

5.0 Water management

5.1 Construct all new facilities on concrete with sealed surfaces for designated traffic routes.

Design of new plant

5.2 Upgrade effluent treatment system to manage new plant waste water.


5.3 Minimize the use of raw water through reuse and recycling of available streams to minimize the amount sent to sewer.

Ongoing

6.0 Waste management

6.1 Explore alternative beneficial reuse of the marc as a biofuel or biomass.

Ongoing

6.2 Maximise use of raffinate as the primary fuel source through engineering controls dependent upon results of stack monitoring.

Ongoing

7.0 Visual amenity

7.1 Ensure building cladding and exterior is matched wherever practical to the existing facilities to minimize visual impact

Design of new plant

8.0 Heritage

8.1 Halt woks and seek relevant advice if items of potential Aboriginal or European heritage are identified during construction.

Design of new plant

9.0 Decommissioning

9.1 Prepare and submit a decommissioning plan as required by the regulatory authority.

As required

10.0 Construction

10.1 Implement DECC (2009) interim construction noise guidelines (or equivalent). Construction activities will only occur during daylight hours.

During construction

10.2 Utilise Export Drive access during construction to minimize traffic hazards on Industrial drive.

During construction



Page 41

5.0 Public consultation

The external stakeholders involved in the planned upgrade include the EPA, Central

Coast Council, local businesses, local fire brigade and crop suppliers including farmers

and haulage contractors. The principal means of consultation with regulatory authorities

(EPA, Central Coast Council, Cradle Mountain Water) will be via the collaborative

development of the Notice of Intent (previously submitted) and subsequent

documentation including this Environmental Effects Report. The Central Coast Council,

and Cradle Mountain Water will be engaged during the preparation of the Development

Application (DA) required to be undertaken prior to any works being undertaken.

A Growers Evening is held twice a year with contractors and suppliers to the site to

forecast crop requirements. This workshop represents the key area of consultation and

provides a forum for feedback on BRA strategic plans.

Adjacent businesses will likely be utilized during construction. Liaison with adjacent

businesses will be included as part of procurement for the construction services.

The local Fire Brigade has been consulted on fire risks and implementation of suitable

upgrades to fire management systems.



Page 42

6.0 References

DCC (2009a). National Greenhouse Accounts (NGA) Factors June 2009. Published by the

Department of Climate Change. Retrieved April 28, 2010 from

www.climatechange.gov.au

DCC (2009b). National Greenhouse Accounts (NGA) State and Territory Greenhouse Gas

Inventories 2007 Retrieved April 28, 2010 from

http://www.climatechange.gov.au/climate-change/~/media/publications/greenhouse-

acctg/state_territory_inventory.ashx

DECC (2009). Interim Construction Noise Guideline, Department of Environment and Climate

Change NSW. Retrieved 22 April, 2010 from

http://www.environment.nsw.gov.au/resources/noise/09265cng.pdf

DTAE (2004). Environment Protection Policy (Air Quality) 2004, Tasmanian Department of Tourism

Arts and Environment. Retrieved 22 April 2010 from

http://www.environment.tas.gov.au/index.aspx?base=82

GAMS (2010). Air Quality in George Town, Tasmanian EPA. Retrieved 5 May, 2010 from

http://www.environment.tas.gov.au/index.aspx?base=168

GHD (2008a). Asphalt Suppliers Pty Ltd C/GHD Hobart Report on Ulverstone Asphalt Plant DPEMP

Acoustic Assessment June 2008 Revision 2. Retrieved 22 April, 2010 from

http://www.epa.tas.gov.au/file.aspx?id=307

GHD (2008b). Asphalt Suppliers Pty Ltd Report on Ulverstone Asphalt Plant Air Quality Assessment

July 2008. Retrieved 22 April, 2010 from http://www.epa.tas.gov.au/file.aspx?id=306

NEPC (2003). National Environment Protection (Ambient Air Quality) Measure. Retrieved May 29,

2010 from http://www.ephc.gov.au/taxonomy/term/23

WST (2009). Dangerous Substances (Safe Handling) Act 2005. Dangerous Substances Locations -

Guide for occupiers. Department of Justice, Workplace Standards Tasmania. Retrieved

5 May, 2010 from

http://www.wst.tas.gov.au/safety_comply/dang_subs/handling/guidance_information



Page 43



Page 44

Appendix 1 Photographs of visual amenity



Page 45

Photo 1 View looking north over BRA site from south of Bass Highway



Page 46

Photo 2 View looking west from corner of Industrial Drive and Kilowat Court



Page 47

Photo 3 View looking North from north west corner of Westella property.





Appendix 2 Stack monitoring results

New Environmental Quality Pty Ltd; Unit 1, 20 Meadow Avenue, Coopers Plains, Qld. 4108

Australia

Page 1 of 12

This document is issued in accordance with NATA’s accreditation requirements.

Accredited for compliance with ISO/ IEC 17025. NATA accredited laboratory 15438.

This report must not be reproduced except in full.

New Environmental Quality

P.O. Box 119

Coopers Plains Qld. 4108

ABN: 56 115 736 046

Source emissions monitoring conducted at the BRA Facility

in Ulverstone, Tasmania

This report provides potentially sensitive information to the reader and as such should be considered a

confidential document. All recipients are required to treat this report as confidential. It is for the sole use

of Environmental Service and Design and those granted permission by Environmental Service and Design.

This report is an initial release

Reviewed by

Prepared by

David Arbuckle

NATA Signatory (QSTI)

Manager

Accreditation Number:

15438

Timon Berger

NATA Signatory (QSTI)

Technical Manager

project ID 00947

issue number 1

client Environmental Service & Design

BRA

issue date 5th

May 2010

testing date 29th

March 2010

contact Mr. Greg Doherty

newEQ is part of the Pacific Environment Limited group of companies

www.pelgroup.com

Report to Environmental Service and Design - BRA newEQ Project ID: 00947

UNCONTROLLED WHEN PRINTED CONFIDENTIAL issue number: 1

New Environmental Quality Pty Ltd Page 2 of 12




EXECUTIVE SUMMARY

Table 1: Results Summary

Source Parameter Test Result Unit of Measure

Boiler Stack

Average velocity 10.2 m/sec

Average stack temperature 269 °C

Average oxygen 14.3 %

Average carbon dioxide 5.02 %

Particulate matter

Concentration 106 mg/Nm

3

Particulate matter

Emission rate 3.71 g/min

Oxides of nitrogen (as NO2)

Concentration 127 mg/Nm

3

Oxides of nitrogen (as NO2)

Emission rate 4.45 g/min

TVOC expressed as n-hexane

Concentrationa 43.1 mg/Nm

3

TVOC expressed as n-hexane

Emission rateb 1.57 g/min

Note: All figures presented above have been rounded up to three significant figures.

a Average of 2 tests (48.0 & 38.1). Refer to results calculation section for more detailed information. b Average of 2 tests (1.75 & 1.39). Refer to results calculation section for more detailed information.







Table of Contents

EXECUTIVE SUMMARY ............................................................................................................................. 2

1.0 INTRODUCTION ........................................................................................................................... 4

2.0 PROCESS DESCRIPTION & EQUIPMENT ....................................................................................... 4

2.1 Process Description ................................................................................................................. 4

2.2 Sampling Location ................................................................................................................... 4

3.0 TEST METHODS & COMMENTS ................................................................................................... 5

3.1 Test Methods ........................................................................................................................... 5

3.2 Test Equipment........................................................................................................................ 6

4.0 QUALITY ASSURANCE & QUALITY CONTROL (QA/QC) ................................................................ 8

5.0 DEFINITIONS ................................................................................................................................ 9

6.0 CALCULATION OF RESULTS ........................................................................................................ 10

LIST OF TABLES

Table 1: Results Summary ....................................................................................................................... 2

Table 2: Test Methods ............................................................................................................................. 5

Table 3: Deviation Notes ......................................................................................................................... 5

Table 4: Analysis Notes ............................................................................................................................ 5

Table 5: Testo 350XL Combustion Gas Analyser specifications .............................................................. 7

Table 6: Sampling data QA/QC checklist ................................................................................................. 8

Table 7: Laboratory Data QA/QC checklist .............................................................................................. 8

Table 8: Definitions .................................................................................................................................. 9

Table 9: Particulate test information .................................................................................................... 10

Table 10: TVOC run 1 test information .................................................................................................. 11

Table 11: TVOC run 2 test information .................................................................................................. 12

Table 12: Document Control ................................................................................................................. 12

LIST OF FIGURES

Figure 1: Full Isokinetic Sampling ensemble (Apex Instruments)............................................................ 6

Figure 2: Testo 350XL Combustion Gas Analyser .................................................................................... 6







1.0 INTRODUCTION

New Environmental Quality was commissioned by Environmental Service and Design to monitor

source emissions from the Botanical Resources Australia Pty. Ltd. facility in Ulverstone, Tasmania.

newEQ was responsible for the collection and analysis of all samples. The collected samples remained

sealed and preserved in the appropriate manner. Upon return to the laboratory the samples were

prepared and analysed by the correct methodologies.

2.0 PROCESS DESCRIPTION & EQUIPMENT

The Botanical Resources Australia facility is located in Ulverstone on the North Coast of Tasmania.

The facility has a boiler that provides heat and steam to the plant process. The boiler has a single

release point that was tested in this project for the parameters listed in table 2.

2.1 Process Description

Botanical Recourses Australia (BRA) Ulverstone site manufactures pyrethrum, derived from a

chrysanthemum daisy. The pyrethrum is extracted and refined using solvent extraction and CO2

refining; this pyrethrum is used as a natural insecticide, of which BRA supply over 45% to the world’s

pyrethrum market.

2.2 Sampling Location

The boiler release stack is located outside and adjacent to the boiler house. The stack is directed

vertically upon exit of the boiler house.

A temporary scaffold was erected to gain access to the sample location, which is at the height of the

shed roof. The probe, filter and impingers were located on the scaffold structure with sample lines

running down to a mobile lab positioned at the base of the stack.







3.0 TEST METHODS & COMMENTS

3.1 Test Methods

Unless otherwise stated, the following test methods meet the requirements of the Tasmanian EPA.

All sampling and analysis was conducted by newEQ unless otherwise stated. The results presented in

this report are related to one or more reference calibrations held by newEQ.

Table 2: Test Methods

Parameter Test Method

NATA

Accreditation

Deviations Analysis

Traverse point selection AS4323.1 Yes A 1

Gas velocity, volume flow rate & temp USEPA Method 2 Yes Nil 1

Stack gas density (O2 and CO2) USEPA Method 3A Yes Nil 1

Moisture content USEPA Method 4 Yes Nil 1

Particulate matter AS4323.2 Yes Nil 1

Oxides of nitrogen USEPA Method 7E Yes Nil 1

Carbon monoxide USEPA Method 10 Yes Nil 1

Total volatile organic compounds (TVOC) USEPA Method 18 Yes Nil 1 & 2

Table 3: Deviation Notes

Note number Comment

A Sample point is located at an ideal distance from any flow disturbances. The access ports are

smaller than that specified in AS4323.1.

Table 4: Analysis Notes

Note Company NATA Accreditation ID Report Number

1 newEQ 15438 00947

2 SGS Environmental 2562 (4354) SE 77569

COMMENTS

1. Stack gas moisture, flow rates and temperature were determined in conjunction with all

isokinetic tests.

2. The release point was not found to exhibit a stratified gas concentration profile.

3. There was a slight visual grey plume during the time of testing.

4. There is an opacity meter mounted on the stack, during the test, this instrument was reading

1.8%.







3.2 Test Equipment

All equipment used during the course of the testing meets or exceeds all relevant performance

standards as required by all jurisdictions. Our isokinetic equipment used for this project was sourced

from Apex Instrumentsc. Note that the probe for this particular test was modified to fit the smaller

sample port size. Combustion gases were monitored using a Testo 350XLd gas analyser.

Figure 1: Full Isokinetic Sampling ensemble (Apex Instruments)

Figure 2: Testo 350XL Combustion Gas Analyser

c http://www.apexinst.com/ d http://www.testo.com.au/







Table 5: Testo 350XL Combustion Gas Analyser specifications

Compound Range Lower Detection Linearity

Limit

O2 1 to 25% 0.1% +/- 0.8% of range

SO2 (not used for this project) 1 to 2,000ppm 1 ppm +/- 5% selected range

CO 1 to 2,000ppm 1 ppm +/- 5% selected range

CO2 0 to 50% 0.01% +/- 1% of range

NO 1 to 3,000ppm 1 ppm +/- 5% selected range

NO2 1 to 500ppm 0.5 ppm +/- 5% selected range

Flow Rate ~ 0.8 liters per minute

Accuracy 2% of span

Span Drift Less than 2% per test

Response Time 40 seconds







4.0 QUALITY ASSURANCE & QUALITY CONTROL (QA/QC)

newEQ operates within a quality system based upon the requirements of ISO17025. Our quality

system defines specific procedures and methodologies to ensure any project undertaken by newEQ is

conducted with the highest level of quality given the specific confines of each project

The overall objective of our QA/QC procedures is to representatively sample and accurately analyse

components in the gas streams and therefore report valid measurements of emission concentrations.

To ensure representativeness of field work our quality procedures target correct sampling locations,

time, frequencies and methods. Along with appropriate sample preservation, chain of custody,

sample preparation and analytical techniques.

newEQ maintains strict quality assurance throughout all it sampling programs, covering on-site ‘field

work’ and the analytical phase of our projects. Our QA program covers the calibration of all sampling

and analytical apparatus where applicable and the use of spikes, replicate sample and reference

standards.

The test methodologies used for this project are outlined in section 3 of this document. Field test

data has been recorded and calculated using direct entry into Microsoft Excel spreadsheets following

the procedures of the appropriate test methods. Determination of emission concentrations has been

performed using the same Microsoft Excel spreadsheets which are partially supplied as an

attachment to this report. More detailed information can be supplied upon request.

QA/QC checks for this project will use validation techniques and criteria appropriate to the type of

data and the purpose of the measurement to approve the test report. Records of all data will be

maintained. Complete chain of custody (COC) procedures has been followed to document the entire

custodial history of each sample. The COC forms also served as a laboratory sheet detailing sample ID

and analysis requirements.

Table 6: Sampling data QA/QC checklist

Sampling Data QA/QC Checklist Comment

use of appropriate test methods Yes

‘normal’ operation of the process being tested Yes

Use of properly operating and calibrated test equipment Yes

Use of high purity reagents Yes

Performance of leak checks post sample (at least) Yes

Table 7: Laboratory Data QA/QC checklist

Laboratory Data QA/QC Checklist

Use of appropriate analytical methods Yes

Use of properly operating and calibrated analytical equipment Yes

Precision and accuracy comparable to that achieved in similar projects Yes

Method 18 recoveries acceptable Yes







5.0 DEFINITIONS

The following terms and abbreviations may be used in this report:

Table 8: Definitions

Symbol Definition

< The analytes tested for was not detected; the value stated is the reportable limit of

detection

Am3 Gas volume in cubic metres at measured conditions

AS Australian Standard

BH Back half of sample train (filter holder and impingers) (referred to during sample recovery) oC Degrees Celsius

dscm dry standard cubic meters

FH Front half of sample train (probe and filter holder) (referred to during sample recovery)

g Grams

kg Kilograms

m Metres

m3 actual gas volume in cubic metres as measured

mb Millibars

mg Milligrams (10-3

grams)

min Minute

ml Millilitres

mmH2O Millimetres of water

Mole SI unit that measures the amount of substance

N/A Not applicable

ng Nanograms (10-9

grams)

Nm3 Gas volume in dry cubic metres at standard temperature and pressure (0°C and 101.3 kPa)

PM Particulate matter

ppm-c Parts per million referenced to carbon

ppm-p Parts per million referenced to propane

sec Second

Sm3

Gas volume in dry cubic metres at standard temperature and pressure (0°C and 101.3 kPa)

and corrected to a standardised value (e.g. 7% O2)

STP Standard temperature and pressure (0°C and 101.3 kPa)

TVOC Total volatile organic compounds

USEPA United States Environmental Protection Authority







6.0 CALCULATION OF RESULTS

Table 9: Particulate test information

Source Data

Client BRA & ESND

Site Ulverstone

Sample Point Boiler

Reference Method AS4323.2

Test Parameters PM

Process conditions Rathenate & Fuel oil

Historical Data & Hardware Information - Manual Sample

Run Start Date Monday, 29 March 2010 dd-mm-yy

Project ID 00947

Run ID -1

Run Start Time Ti 17:13:00 hh:mm

Run Stop Time Tf 18:13:00 hh:mm

Positioning compliance check with AS4323.1 Non-ideal

Flow & temperature compliance check with AS4323.1 YES

Traverse pt factors; up, down, total & trav pts 1 , 1 , 1 , 8

Console Serial Number SN256

Meter Calibration Factor (Y) 0.99

Orifice Coefficient 42.03 ( H@)

Pitot Tube Coefficient (Cp) 1.00

Actual Nozzle Diameter (Dna) 7.46 mm

Stack Test Data

Initial Meter Volume (Vm)i 248.6560 m3

Final Meter Volume (Vm)f 249.4320 m3

Total Sampling Time ( ) 1:00:00 hh:mm:ss

Average Meter Temperature (tm)avg 23.40 oC

Average Stack Temperature (ts)avg 268.63 oC

Barometric Pressure (Pb) 1007 mb

Stack Static Pressure (Pstatic) 8.90 mm H2O

Absolute Stack Pressure (Ps) 1008 mb

Sample Volumes

Actual Meter Volume (Vm) 0.7667 m3

Standard Meter Volume (Vm)std 0.7030 Nm3

Moisture Content Data

Impingers 1-3 Water Volume Gain (Vn) 20.0 ml

Impinger 4 Silica Gel Weight Gain (Wn) 5.2 g

Total Water Volume Collected (Vlc) 25.2 ml

Calculated Stack Moisture (Bws(calc)) 7.79 %

Stack Gas Density Analysis Data

Carbon Dioxide Percentage (%CO2) 5.02 %

Oxygen Percentage (%O2) 14.29 %

Carbon Monoxide Percentage (%CO) 0.23 %

Nitrogen Percentage (%N2) 80.47 %

Dry Gas Molecular Weight (Md) 1.31 kg/Nm3

Dry Gas Molecular Weight (Md) 29.37 g/g-mole

Wet Stack Gas Molecular Weight (Ms) 28.49 g/g-mole

Volumetric Flow Rate Data (at Sample Plane)

Average Stack Gas Velocity (vs) 10.11 m/sec

Stack Diameter Ds 0.40 m

Stack Cross-Sectional Area (As) 0.13 m2

Upstream distance (from disturbance) B 2.50 m

Downstream distance (from disturbance) A 15.00 m

Actual Stack Flow Rate (Qaw) 76.221 m3/min

Wet Standard Stack Flow Rate (Qsw) 38.224 Nm3/min-wet

Dry Standard Stack Flow Rate (Qsd) 35.245 Nm3/min-dry

Percent of Isokinetic Rate (I) 102.4 %

Particulate Matter (PM) Concentration

Total Mass of Particulates (mn) 0.07405 g

Stack PM Concentration (cs) 105.34 mg/Nm3

Particulate Emission Rate (E) 3.71 g/min

Historical Data & Hardware Information - Instrumental Analyser

Analyser serial number, make & model SN027 , TESTO 350XL value

Analyser Run Start Time Ti 17:19:51 PM hh:mm

Analyser Run Stop Time Tf 18:13:53 PM hh:mm







Instrumental Analyser Raw Data Averages

Oxides of Nitrogen (NOx) 61.7 ppm

Carbon Monoxide (CO) 2273.9 ppm

Average Oxides of Nitrogen (USEPA Method 7E - instrumental analyser)

Nitrogen Oxides (NOx) (Conc) 126.4 mg/Nm3

Nitrogen Oxides (NOx) (Conc) (7% O2) 0 265.6 mg/Nm3

Nitrogen Oxides (NOx) (E) 4.45 g/min

Average Carbon Monoxide (USEPA Method 10 - instrumental analyser)

Carbon Monoxide (CO) (Conc) 2842.4 mg/Nm3

Carbon Monoxide (CO) (E) 100.2 g/min

Table 10: TVOC run 1 test information

Source Data

Client BRA & ESND

Site Ulverstone

Sample Point Boiler

Reference Method USEPA M18

Test Parameters TVOC



Project ID 00947

Run ID -2



Positioning compliance check with AS4323.1 Ideal






Stack Test Data









Sample Volumes






















TVOC (USEPA Method 18)

Total volatile organic compounds (as n-hexane) (Conc) 0.00 47.96 mg/Nm3

Emission rate (E) 1.75 g/min

(R) value R 0.72







Table 11: TVOC run 2 test information

Source Data

Client BRA & ESND

Site Ulverstone

Sample Point Boiler

Reference Method USEPA M18

Test Parameters TVOC



Project ID 00947

Run ID -3



Positioning compliance check with AS4323.1 Ideal






Stack Test Data









Sample Volumes






















TVOC (USEPA Method 18)

Total volatile organic compounds (as n-hexane) (Conc) 0.00 38.05 mg/Nm3

Emission rate (E) 1.39 g/min

(R) value R 0.72

Table 12: Document Control

Report ID Date Comment Author Quality Released to

00947-1 05/05/10 Initial release TB DA Greg Doherty

Date post:	16-May-2020
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